The author, in this article, examines Japan's Tax Reform 2009/10, with special reference to the background to the reform, the relevant legislative amendments regarding the taxation of controlled foreign subsidiaries and the implications of the reform for the future

The cash-flow tax has been proposed as an alternative to corporate income tax on grounds of clarity and simplicity in defining the tax base in the face of widespread departures from the comprehensive income tax in actual practice. Variants of the tax, with their advantages and disadvantages,...

This work undertakes a comprehensive analysis of the U.S. state experience under formulary apportionment of corporate income. While formulary apportionment eliminates the possibility of shifting income across states through accounting strategies that manipulate where income is booked, it may...

A surprising degree of bipartisan consensus has lately formed in the United States around two propositions of business tax reform: that something should be done about the “lockout” of U.S. multinationals' foreign earnings; and that (for reasons that go beyond lockout) the corporate income...

This comment letter addresses Senate Finance Committee Chair Ron Wyden’s International Tax Reform Framework Discussion Draft released August 25, 2021 (with Senators Brown and Warner) (the WBW Draft). The comment discusses why U.S. multinationals have competitive advantages compared to...

The game Prisoner's Dilemma provides a helpful tool for understanding international tax competition. Nations would be best served by cooperating with each other to keep corporate income tax rates high. But fearing defection by other nations, many nations often unilaterally lower their corporate...

The main purpose of this book is to promote the dissemination of the basic notions of taxation from a policy, legal and administrative perspective, offering its readers a balanced view of rights and obligations connected with the levying of taxes. The book sets out current principles of taxation...

This paper examines the effects of the Tax Reform Act of 1986 on the international location decisions of U.S. financial services firms. The Act included rule changes that made it substantially more difficult for U.S. firms to defer U.S. taxes on overseas financial services income held in low-tax...